One of the monthly features in our magazine, Banking on BCC, is the Q & A Corner. Each month, we share some of the questions we’ve received related to lending, deposit and BSA/AML/CFT compliance. Here are a few of the deposit questions we’ve covered this past year.
Question: When advertising a deposit account via email, what are the requirements? Are one-click-away disclosures acceptable?
Answer: An email would be similar to a webpage or social media advertisement. So, if the email includes an annual percentage yield (APY) or mentions a bonus, additional disclosures would be triggered. You can find these in §1030.8. You could include a link to the additional disclosures; just keep in mind that when the reader clicks on the link, it must take them directly to the additional disclosures; thus, the reason it is called “one-click-away”.
Question: If we decide to close a customer’s account based on their account activity and not on information in a consumer report, do we still need to send an adverse action notice?
Answer: Since the adverse action was not based on information in a credit report, the FCRA notices are off the table. If you are taking some kind of adverse action on a loan, you would still need to provide a notice under Regulation B. If you are closing a deposit account, no adverse action notice would be required. While you certainly could send a notice of the deposit account closure, it’s not required.
Question: Does The Truth in Savings Act (TISA) require us to use either the daily balance method or average daily balance method for certain types of accounts?
Answer: No. TISA gives you flexibility to decide which method you want to use. Just make sure that the method disclosed is what your system is actually using. But keep in mind that an institution needs to … use the same method to determine any minimum balance required to earn interest as it uses to determine the balance on which interest is calculated.
Other monthly features include:
- “Field Notes” – Our Review Team highlights issues they have seen during their reviews to raise awareness.
- “BSA Bits & Pieces” – We address new and old topics specific to BSA/AML/CFT compliance.
- “Management Minute” – This provides information from a Management and Board perspective.
- “Training Spotlight” – A one-stop shop to see what training options we have available that month.
We would love to have you check it out!
Published
2025/12/15
